On 2008 Jan 26 , at 9:51 AM, Remek Kocz wrote:
There are only 2 more days remaining to submit comments on Notice
No. 73 regarding labeling of alcoholic beverages.
After one aborted attempt I finally completed their response form but
am still unsure if it went through OK. It did not appear to do so
because it gave no message thanking me for my input or indicating that
it had been received. Instead, it just reprinted my form (name
address etc) and my message. I hope it went through because I spent
some time doing it (twice).
Anyway, if interested, below is what I wrote to them.
Regards,
Bill Hooper
Fernandina Beach, Florida, USA
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SImplification Begins With SI.
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Regarding Notice No. 73 -- Labeling and Advertising of Wines,
Distilled Spirits and Malt Beverages
I wish to urge the adoption of rules that would require the use of
metric measures on labels, preferably only metric only. The SI metric
System has been designated by Congress to be the preferred system of
measures for the US. The labeling rules should reflect that
designation. I offer two specific suggestions based on statements in
Notice #73.
The notice states:
“Industry members may also choose to disclose on the Serving Facts
panel the number of U.S. fluid ounces of pure alcohol (ethyl alcohol)
per serving …”
However, it is preferable that the volume per serving size be given in
metric measures, and therefore should be in millilitres (mL) rather
than in fluid ounces (fl. oz.).
The notice also states:
“TTB also proposes to require a Serving Facts panel on alcohol
beverage labels, which would include a statement of calories,
carbohydrates, fat, and protein.”
First I note that the statement fails to specify what is to be
measured in calories. The notice should identify this quantity to be
the “food energy”. (I have used the term “food energy”, but there are
other terms that might be used to describe it. Examples are: “caloric
energy” and “nutritional energy”.
Second, calories are not an acceptable unit in the SI metric system.
The correct SI unit is the joule (J) or one of its multiples such as
the kilojoule (kJ). A kilojoule is, of course, 1000 joules. If the
calorie is the nutritional calorie, which is likely here, then it is
equal to 4184 J or 4.184 kJ. (There are several other calories, most
of which are a thousand times smaller than the nutritional calorie.
This confusion of calories is one of the primary reasons for replacing
such old units with metric units in the first place.)
Secondly in the quoted text above, the statement fails to indicate
what measure of the carbohydrates, fats and protein are to be printed
on the label. Those amounts might be the volumes of those materials,
or they might be the masses, or perhaps something else. The intended
quantity probably is the mass*. In SI metric those masses would be in
grams (g) or a sub-multiple of the gram, such as milligram (mg).
Certainly the use of grams and milligrams is preferable to the use of
ounces (not fluid ounces but mass ounces here) or pounds or grains etc.
*(I use the technically correct term “mass” here. Frequently, even in
law, this quantity is called “weight”. Strictly speaking, weight is
the force of gravity pulling down on a mass. However, forces are
measured in newtons, not grams, in the metric system.)
I appreciate your kind consideration of my views on these points. It
is to be hoped that all such regulations can more thoroughly specified
in metric measures in the near future.
Sincerely,
(Dr.) William Hooper
Certified Advanced Metric Specialist
Professor of Physics (retired) from
The University of Virginia’s College at Wise
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